Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
ITAT allowed the assessee-firm's appeal and deleted the addition made u/s 69A r/w s.115BBE on account of partners' capital introduction. It held that payments for land purchase were substantially made directly by partners from their bank accounts and duly reflected in registered sale deeds and corresponding journal entries, rendering the AO's factual assumption erroneous. ITAT further held that any unexplained capital introduced by partners is assessable, if at all, in the hands of the respective partners and not the firm. The statutory requirement to prove "source of source" inserted in s.68 w.e.f. 01.04.2023 was held inapplicable to AY 2017-18.
ITAT allowed the assessee-firm's appeal and deleted the addition made u/s 69A r/w s.115BBE on account of partners' capital introduction. It held that payments for land purchase were substantially made directly by partners from their bank accounts and duly reflected in registered sale deeds and corresponding journal entries, rendering the AO's factual assumption erroneous. ITAT further held that any unexplained capital introduced by partners is assessable, if at all, in the hands of the respective partners and not the firm. The statutory requirement to prove "source of source" inserted in s.68 w.e.f. 01.04.2023 was held inapplicable to AY 2017-18.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
